The Northwest Power Act directs the Council to adopt and include in its power plan a conservation program that includes model conservation standards (MCS). The MCS are applicable to (i) new and existing structures; (ii) utility, customer, and governmental conservation programs; and (iii) other consumer actions for achieving conservation. The Act requires that the standards reflect geographic and climatic differences within the region and other appropriate considerations. The Act also requires that the Council design the MCS to produce all power savings that are cost-effective for the region and economically feasible for consumers, taking into account financial assistance from the Bonneville Power Administration and the region’s utilities.
In addition to the requirements set forth in the Act, the Council believes the model conservation standards in the plan should produce reliable savings and that the standards should, where possible, maintain and improve upon the occupant amenity levels (e.g., indoor air quality, comfort, window areas, architectural styles) found in typical buildings constructed before the first standards were adopted in 1983.
The Power Act provides for broad application of the MCS. In the earlier plans, a strong emphasis was needed to improve residential and commercial building construction practices beyond the existing codes. Beginning with the first standards adopted in 1983, the Council has adopted a total of seven model conservation standards. These include the standard for new electrically heated residential buildings, the standard for utility residential conservation programs, the standard for all new commercial buildings, the standard for utility commercial conservation programs, the standard for conversions to electric heating systems, and the standard for conservation programs not covered explicitly by the other model conservation standards. Since the Council adopted its first model conservation standards, all four states within the Northwest have adopted strong energy codes that incorporate the standards.
MCS Overview
The MCS for the 2021 Power Plan have two main components. The first is that the Council adopts two specific components to the standards to ensure equity in efficiency adoption through codes and standards. The second component provides the standard for conversions (similar to prior MCS) to an electric space or water heating system from another fuel.
The focus of the condes and standards component of the MCS is on two areas intended to improve equity around efficiency acquisition through codes and standards. These areas include supporting common appliance standards in the Northwest and discouraging backsliding or reducing codes or standards.
In addition, as municipalities around the region are considering reducing their carbon footprint, electrification of end-use equipment has gained interest. The second component of the MCS is the standard for conversions (similar to prior MCS) to an electric space or water heating system from another fuel. The Act definition of conservation clearly excludes fuel switching as energy efficiency. However, if fuel switching were to be promoted, this MCS directs action to ensure the switching is performed with all cost-effective electric energy efficiency incorporated.
Common Appliance Standards
The minimum efficiency requirements of many appliances and equipment are regulated at the federal level (https://www.energy.gov/eere/buildings/appliance-and-equipment-standards-program). These standards are a low-cost, equitable means of achieving cost-effective efficiency. For products without a federal standard, states may adopt their own minimum efficiency requirement. In the past few years, several states have adopted their own standards, including Washington and Oregon. Often, these standards are consistent with those in California, allowing for a uniform market in the western most United States. This commonality is preferred by manufacturers to minimize regulatory confusion and multiple product lines. To further efficiency and limit market disruption, Northwest states should consider adopting common standards and work to synchronize updates. Coordinating with additional states, such as through initiatives by the Appliance Standards Awareness Project, would strengthen the likelihood of compliance and manufacturer buy-in.
No Backsliding on Codes or Standards
Once a code or standard has been adopted, no state or federal agency should change the standard such that a subset of buildings or appliances are subject to a less stringent standard. Codes and standards are a low-cost, equitable means of achieving cost-effective conservation. When markets are segmented into product classes and thus subject to differing requirements, this dilutes the efficacy of the code or standard and decreases efficiency. This in turn has impacts on the ability for the region to equitably provide low-cost energy efficiency to all Northwest consumers.
Conversion to Electric Space Conditioning and Water Heating
Per the Power Plan analysis, jurisdictions pursing economy-wide decarbonization goals should pursue multiple approaches to reduce carbon, including significant energy efficiency investment. Those jurisdictions (state or local governments) or utilities with such decarbonization goals should take actions through codes, service standards, user fees or alternative programs, or a combination thereof, to achieve electric power savings from buildings. These savings should be comparable to those that would be achieved if each building converting to electric space conditioning or water heating were upgraded to include related conservation measures at least as efficient as the lowest-efficiency measure included in the 2021 Plan or adopted by the RTF (whichever is more recent). While some of the measures may not be cost-effective under the Council’s current methodology, the Council believes they would be for jurisdictions with deep decarbonization initiatives. Similarly, for those jurisdictions, any existing inefficient electrical space or water heating equipment, these should also be upgraded to a minimally efficient level at time of replacement.[1]
[1] There may be cases where the savings are minimal relative to the expense (e.g. installing ductless heat pumps in small multifamily units) and may not be a priority efficiency investment. Jurisdictions will need to consider policy goals in determining what a reasonable cost-effectiveness limit should be.